Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Refund claim - unjust enrichment - Initially claim filed without challenging the self-assessed Bills of Entry - During the appeal process, the appellant sought to amend the bills of entry, which was initially rejected but later allowed by the High Court. The High Court directed the amendment of bills of entry to reflect the correct duty rate, enabling the appellant to seek a refund of excess duty paid. Following the High Court's directive, the Adjudicating Authority granted the refund, stating that there was no unjust enrichment based on evidence provided.
Refund claim - unjust enrichment - Initially claim filed without challenging the self-assessed Bills of Entry - During the appeal process, the appellant sought to amend the bills of entry, which was initially rejected but later allowed by the High Court. The High Court directed the amendment of bills of entry to reflect the correct duty rate, enabling the appellant to seek a refund of excess duty paid. Following the High Court's directive, the Adjudicating Authority granted the refund, stating that there was no unjust enrichment based on evidence provided.
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